The Food Safety Modernization Act (FSMA), is focused on preventing, rather than responding to, contamination in the U.S. food supply. The act is divided into four key sectors:

• Prevention
• Inspection
• Compliance and response
• Import safety

Each sector is further divided into subsections of best practices, covering all aspects of food safety management.  FSMA provisions requires an increase in documentation.

FSMA Title 1 Section 103 focuses on hazard analysis and risk based preventative controls. As part of the preventive measures, food manufacturers will be required to create a Food Safety Plan that documents and describes the facility‘s preventive controls procedures. The plan would need to be available to the FDA upon request.

Four important aspects of the Food Safety Plan are:

1. Identify the hazards and understand the cause
2. Implementation of preventive controls designed to significantly minimize or prevent hazards
3. Monitoring to ensure the controls are effective or to take action if they are not
4. Verify to ensure that the controls have the desired effect of reducing the risk of contamination in the facility

Lubrication is a relevant component of a Food Safety Plan

Lubrication is an important component which should be taken into account in a Food Safety Plan. Failure to include lubricants and lubrication safety in a Food Safety Plan can lead to costly product recalls and damage to the brand image of the food manufacturer.

Within the implementation stage of the Food Safety Plan, one of the preventive controls to minimize hazards is using the appropriate lubricant on machinery where there is a possibility of any incidental contact between the food and lubricant.

It is imperative that the lubricant used in these areas meets the guidelines set by the Food and Drug Administration (FDA) under FDA Title 21 CFR 178.3570. The lubricants meeting the criteria laid out in FDA Title 21 are typically registered as NSF H1 by NSF International. Lubricants with incidental food contact may be safely used on machinery used for processing and packaging food.

In addition to using the NSF H1 lubricant for incidental food contact applications, a food manufacturing facility should consider implementing the following in their Food Safety Plan :

• Lubrication HACCP study to identify lubrication hazards that could affect food safety
• Best practices on lubricant storage, application and disposal
• Best practices on lubrication 5S
• Training for supervisors and employees on lubrication and food safety

A strong Food Safety Plan and its implementation is key for food manufacturers.

More info on FSMA can be found at www.fda.gov/Food/GuidanceRegulation/FSMA/